Patterson v. McClean Credit Union case
brief summary
491 U.S. 164, 109 S. Ct. 2363, 105 L. Ed. 2d 132 (1989)
491 U.S. 164, 109 S. Ct. 2363, 105 L. Ed. 2d 132 (1989)
CASE SYNOPSIS: Petitioner employee
sought a writ of certiorari from a judgment of the United States
Court of Appeals for the Fourth Circuit, which affirmed the decision
that her racial harassment claim against respondent employer was not
cognizable under 42 U.S.C.S. § 1981 and that, in her discrimination
claim, she had to prove she was better qualified than the white
employee who was promoted in her stead.
CASE FACTS: The employee sought damages for racial harassment and for discrimination under 42 U.S.C.S. § 1981.
CASE FACTS: The employee sought damages for racial harassment and for discrimination under 42 U.S.C.S. § 1981.
DISCUSSION
- The Court held that harassment relating to the conditions of her employment was not actionable under § 1981 because, under the rule of stare decisis, that provision did not apply to conduct that occurred after the formation of the contract and did not interfere with the right to enforce established contract obligations.
- With the exception of the refusal to promote claim, none of the conduct that petitioner alleged was racial harassment involved either a refusal to make a contract or the impairment of her ability to enforce her contractual rights.
- However, the failure to promote was actionable under § 1981 because it involved her ability to enter into a new contract with her employer.
- The appeals court erred in holding that the employee could succeed in her discriminatory promotion claim only by proving that she was better qualified for the position than the white employee who was promoted.
- The employee was not limited to presenting evidence of a certain type in order to demonstrate that the employer's proffered reasons for its decision were not its true reasons.
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